1. By way of this appeal, the appellant has challenged the judgment and order of the tribunal whereby the tribunal has partly allowed the appeal filed by the assessee and modified the order of CIT(A) to the extent of partly allowing the appeal.

2. This court while admitting the appeal on 21.2.2017 framed following substantial question of law:—

“1. Whether on the facts and material available on record and in law the ld. ITAT was justified in holding that the assessee appellant was not entitled to exemption u/s 10(23C)(iiiab)/10(23C)(iv) of the Act”?

3. The facts of the case are that assessee appellant is an autonomous body established for the purpose of publication of books in Hindi language for post graduate student of Universities in India as per the Education Policy decision of the Ministry of Education & Social Welfare, Department of Education, Government of India.

4. The Board is functioning in public interest with no motive of profit or for profit. The Board is functioning under the management, Control & Supervision of the Government of Rajasthan. As per the directio